Modern Slavery Report

MODERN SLAVERY STATEMENT

We are committed to running our business in line with our values and work to prevent modern slavery throughout our organisation and in our supply chain.

ASSESSING RISK AREAS

Utilising the information provided in the Global Slavery Index, areas of higher risk and areas of greater and lesser activity to prevent modern slavery are identified. We have again reviewed this and note that there are no significant changes to the position as it affects our Company.

A significant proportion of our furniture is manufactured outside Europe. This is an area identified as higher risk and is monitored internally. It is however important to also maintain a vigilance in other areas of the globe and in the home UK market.

STEPS TAKEN TO PREVENT MODERN SLAVERY

We prohibit all areas of its business and supply chain from using slavery and human trafficking of any kind. Sterling Furniture also accedes that it is impossible to eradicate all events and is keen to play its part in influencing what it can.

Our internal protection against modern slavery is to ensure that all business activity complies with the minimum wage legislation. This is also expected of contractors. We have the checks in place to ensure that all employees and workers have the right to work in the UK and requires that UK contractors only employ staff with the right to work in the UK.

We are a member of a buying group, Associated Independent Stores (AIS) based in Solihull. AIS co-ordinates and monitors the buying from and suppliers of both furniture and homewares. AIS employs independent consultants based in Hong Kong, who visit and audit the manufacturers in the Far East, including China, Vietnam, Philippines. The Covid-19 global pandemic affected the ability for travel and visits to factories were curtailed but this has now started to open up. There continues to be other global challenges as far as travel and direct access is concerned and parts of the Far East still have significant impact through the pandemic. We are aware of this vulnerability and deviation from our normal programme and will look to seeing that they are reinstated as soon as the restrictions allow. We have appointed a Compliance Manager to this end.

In addition, our buyers and quality controllers would normally visit our manufacturers and suppliers, including those in the Far East, and make an assessment as part of the buying and SLA negotiations. As stated, tackling the aspect of modern slavery has its limitations in a remote platform but ‘normal’ business will resume as soon as restrictions and challenges allow.

Buyers across the membership of AIS are encouraged to feed into AIS on any areas of concern or evidence of modern slavery. A significant number of our suppliers have been supplying product to us for many years and relationships build over time. Complacency is however not an option and the checks above are also relevant to the ongoing supply chain arrangements.

TRAINING

Our Buyers have been trained to recognise potential risks and to highlight areas of concern. The Payroll Team has been trained on the legislation and papers required to prove the right to work in the UK. Managers have received training to intercede at point of interview with regards to the rights to work in the UK and this will be on going to refresh knowledge.

OUR NEXT STEPS

We will continue to work with suppliers, with the identification and prevention of Modern Slavery on the agenda for business negotiations and SLAs. We have developed a process of gathering feedback and information from our new suppliers and this will be on-going. Development of a factory profile questionnaire continues to be developed - to be completed by potential new factories to learn about their technical and ethical profile - assisting our Buyers in assessing the risk.

This statement is made pursuant to section 54(l) of the Modern Slavery Act 2015 and constitutes Sterling Furniture Group’s slavery and human trafficking statement for the financial year ending February 2022.

Lesley Graham

Buying Director

25th September 2022